HomeMy WebLinkAboutWQ0029804_Non-Discahrge Compliance Evaluation Inspection Report_20210816ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
August 16, 2021
Ms. Courtney Driver - Utilities Director
Winston-Salem/Forsyth County Utilities Commission
Post Office Box 2511
Winston-Salem, North Carolina 27102
SUBJECT: Compliance Evaluation Inspection
Winston-Salem/Forsyth County Utilities Commission
Thermal Biosolids Drier Management Facility/Residuals Distribution Program
Permit No. WQ0029804
Forsyth County
Dear Ms. Driver:
On August 3, 2021, staff of the North Carolina Division of Water Resources (DWR) Winston-Salem Regional
Office performed a compliance inspection of the subject facility and the residuals distribution program. This
inspection was performed by DWR representatives Jim Gonsiewski and Caitlin Caudle. The compliance
inspection report for this inspection is enclosed for your review. The inspection of the thermal biosolids dryer
facility and residuals distribution program reflects compliance with permit WQ0029804.
Our office appreciates your diligence in properly maintaining your thermal biosolids dryer facility and
residuals distribution program. Please refer to the enclosed compliance inspection report for additional
observations and comments. If you or your staff have any questions concerning this letter, please contact me
or Jim Gonsiewski at (336) 776-9800 or via email at jim.gonsiewski@ncdenr.gov.
Sincerely,
DoeuSIgned by:
v 0D2D3CE3F167458...
Jennifer F. Graznak
Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
enc.: Compliance Inspection Report
cc: Forsyth County Environmental Health (Electronic Copy)
Mr. Frank Crump - WWTP Superintendent, City of Winston-Salem (Electronic Copy)
Mr. Chris Shamel - Assistant WWTP Superintendent, City of Winston-Salem (Electronic Copy)
Mr. Bruce Casey — Drying Facility Supervisor, City of Winston-Salem (Electronic Copy)
Ms. Diane Herndon — Residuals Technician, City of Winston-Salem (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800
Compliance Inspection Report
Permit: WQ0029804 Effective: 05/01/20 Expiration: 06/30/26 Owner : City of Winston-Salem
SOC: Effective: Expiration: Facility: City of Winston-Salem DCAR
County: Forsyth 2801 Griffith Rd
Region: Winston-Salem
Contact Person: Bruce Michael Casey
Directions to Facility:
Winston Salem NC 27103
Title: Utilities Plant Supervisor Phone: 336-397-7662
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/03/2021 Entry Time 10 OOAM
Exit Time: 12:10PM
Primary Inspector: Jim J Gonsiewski Phone: 336-776-9704
Secondary Inspector(s):
Caitlin Caudle
Reason for Inspection: Routine
Permit Inspection Type: Distribution of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
El Miscellaneous Questions
El Sampling
(See attachment summary)
Inspection Type: Compliance Evaluation
Record Keeping • Treatment
Page 1 of 4
Permit: WQ0029804 Owner - Facility:City of Winston-Salem
Inspection Date: 08/03/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On August 3,2021, staff of the North Carolina Division of Water Resources (DWR) Winston-Salem Regional Office performed
a compliance inspection of the subject facility and the residuals distribution program. This inspection was performed by
DWR representatives Jim Gonsiewski and Caitlin Caudle. The inspection of the thermal biosolids dryer facility and residuals
distribution program reflects compliance with permit WQ0029804.
Page 2 of 4
Permit: WQ0029804 Owner - Facility:City of Winston-Salem
Inspection Date: 08/03/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Tyge
Distribution and Marketing
Land Application
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment:
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Yes No NA NE
Yes No NA NE
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❑ 0110
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Yes No NA NE
0
0
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Page 3 of 4
Permit: WO0029804 Owner - Facility:City of Winston-Salem
Inspection Date: 08/03/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Comment: Resivals are primarily heat treated to form Class A pellets which are transported off site by
Granville Farms for land application. Any residuals which can't be treated are transported to
the Winston-Salem landfill for disposal.
Sampling
Describe sampling:
Is sampling adequate?
Is sampling representative?
Comment:
Yes No NA NE
■❑❑❑
11000
Page 4 of 4
North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Section
NON -DISCHARGE COMPLIANCE INSPECTION REPORT
CLASS A RESIDUALS DISTRIBUTION
General Information
Facility Name: Winston-Salem WWTP County: Forsyth
Permit No.: WQ00 29804 Permit Issuance Date: 02/17/20
Owner: City of Winston-Salem
Plant ORC Name: Bruce Casey
Other Contact(S): Diane Herndon
Permit Expiration Date: 06/30/26
Telephone No.: 336-397-7662
Telephone No.: 336-397-7624
Facility Location (address, gps or directions): 2801 Griffith Road Winston-Salem NC
Reason for Inspection
® ROUTINE ❑ FOLLOW-UP ❑ COMPLAINT ❑ PERMITTING ❑ Other:
Comments (attach additional pages as necessary)
Arrived at the facility at 10:00 AM. Met with Bruce Casey, Drying Facility Supervisor, and
Diane Herndon, Residuals Technician. Discussed the current conditions at the facility. The
system went through several shutdowns in 2021. The Stada Computer system was
upgraded in March with a new system. Also in March the furnace was shut down for
several weeks and recoated with stainless steel. The drum was also recoated with stainless
steel in May with the shutdown lasting 3 weeks. The next scheduled shutdown will be for a
NFPA dust hazard upgrade for approximately six weeks in late 2021 to early 2022.
Granville Frams of Oxford NC loads and distributes the finished Class A pellets.
Toured facility. The facility was operational. The refurbished furnace and drum have led to
higher temperatures in the system. There is a concern for holding times for fecal coliform
samples since the high temperatures lead to longer cooling times for the samples. Rapid
cooling can lead to condensation in the sample bottles. POTW personnel are working on a
solution to this.
Is a follow-up inspection necessary? ❑ Yes 7 No
Primary Inspector: Jim Gonsiewski
Date of Inspection: 08/03/2021
Secondary Inspector: Caitlin Caudle
Entry Time: 10:00 AM Exit Time: 12:10 PM
Non -Discharge Compliance Inspection Report
Record Keeping and Reporting Information: Y N NA NE
Is current permit and prior annual reports available upon request? ❑ ❑ ❑ ❑
Has the facility been free of public complaints for the last 12 months? {0] ❑ ❑ ❑
TCLP analysis conducted and results available? Frequency? annual(See permit for frequency) ® ❑ ❑ ❑
Residuals metals and nutrient analysis conducted? Frequency? monthb (See permit for frequency) ® ❑ ❑ ❑
Nutrient and metals loading calculations? (to determine most limiting parameter) ❑ ODD
Do lab sheets support data reported on Residuals Analysis Summary? ® ❑ ❑ ❑
Are distribution and/or hauling records available? ODD
Utilization Agreements established or Recipient Notifications available for review? DOD
Do the Utilization Agreements or Recipient Notifications contain minimum requirements? ODD
(Restrictions for land application, stockpiling, setback buffers, etc.)
If the Permittee applies bulk residuals, are field loading records available? ❑ ❑ D ❑
If the Permittee applies bulk residuals, are field inspections conducted and are records available? EID ® ❑
Does residuals package label or Utilization agreement contain minimum info required by permit? ❑ ❑ {Z ❑
(Name & address of generator, statement of restrictions, nutrient contents)
Is an inspection log available containing record of residuals facility inspections, maintenance, 0 ❑ ❑ ❑
and repairs?
Pathogen and Vector Attraction Reduction Records
Pathogen Reduction: Requires both pathogen density demonstration and Class A treatment alternative.
Fecal Coliform density or ❑ Salmonella density to demonstrate pathogen requirements. Y N NA NE
Was sampling conducted at the permit required frequency? (See permit for frequency) ® ❑ ❑ ❑
Were multiple samples taken? ODD
If Fecal Coliform, density <1,000 MPN/gram of total solids? ❑ ❑ ❑
If Salmonella, density <3 MPN/4 grams of total solids? ❑ ❑ ® ❑
Select which treatment Alternative below was used to demonstrate Class A compliance.
❑ Alternative 1 - Time/Temperature (See White House Manual for specific requirements) Y N NA NE
Were residuals maintained for correct time and temperature? DODO
Are logs present showing time and temperature? DODD
Are temperatures within range for complete time period? DODD
❑ Alternative 2 - Alkaline Treatment
Are logs present showing time and temperature? ❑ ❑ ❑ ❑
Was the pH raised to 12 or greater and maintained for 72 hours or longer? DODO
Was the temperature 52°C (126°F) for 12 hours or longer while the pH was 12 or greater? ❑ ❑ ❑ ❑
Are logs present showing time and pH? ❑ ❑ ❑ ❑
Was the temperature corrected to 25°C (77°F) by calculation, NOT autocorrect? ❑ ❑ ❑ ❑
❑ Alternative 5 - Process to Further Reduce Pathogens (PFRP) [Select the PFRP method below that was utilized]
❑ Composting, Select which method was used:
❑ Within -Vessel Method or Static Aerated Pile Method
Were residuals temperatures maintained at >55°C (131°F) for Y N NA NE
>3 consecutive days in the within -vessel or static aerated piles? ❑ ❑ ❑ ❑
❑ Windrow Composting Method
Were the residuals temperatures maintained at >55°C for at least
15 consecutive days in the windrow, and the windrow was turned a
minimum of five times during this time?
❑ Heat Drying
Were the residuals dried by direct or indirect contact with hot gases and the
moisture content of residuals reduced to <10%?
Did the temperature of the residuals or the wet bulb temperature of the gas
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0 ❑ ❑ ❑
in contact with the residuals as the residuals leave the dryer exceed 80°C (176°F)?
❑ Other Alternative, Specify: (See White House Manual)
Page 2 of 4
Non -Discharge Compliance Inspection Report
Vector Attraction Reduction:
Select which Option was used to demonstrate compliance and complete answer associated questions.
❑ Option 1 - 38% Volatile Solids Reduction Y N NA NE
Are lab results and calculations present? DODO
Was the reduction on volatile solids (not total solids)? ❑ ❑ ❑ ❑
Were samples collected at correct locations? ❑ DOD
(beginning of digestion process & before land application)
Was there a >38% reduction? ❑ DDO
❑ Option 2 - 40-Day Bench Scale Test Y N NA NE
Were residuals from anaerobic digestion? ❑ ODD
Are lab results and calculations present? ❑ ❑ ❑ ❑
Was the test anaerobically digested in lab, and test run for 40 days? ❑ DOD
Was the test done between 30°C (86°F) and 37°C (99°F)? ❑ DOE
Was the reduction of on volatile solids (not total solids)? ❑ ❑ ❑ ❑
Was the reduction less than 17%? ❑ ❑ ❑ ❑
❑ Option 3 - 30-Day Bench Scale Test Y N NA NE
Were residuals from aerobic digestion? ❑ ❑ ❑ ❑
Are lab results and calculations present? ❑ ❑ ❑ ❑
Were residuals 2% or less total solids? ❑ ❑ ❑ ❑
If not 2% total solids, was the test ran on a sample diluted to 2%
with unchlorinated effluent? ❑ ❑ ❑ ❑
Was the test run for 30 days? ❑ ❑ ❑ ❑
Was the test done at 20°C (68°F)? ❑ ❑ ❑ ❑
Was the reduction of on volatile solids (not total solids)? ❑ ❑ ❑ ❑
Was the reduction less than 15%? ❑ ❑ ❑ ❑
❑ Option 4 - Specific Oxygen Uptake Rate (SOUR Test) Y N NA NE
Were residuals form aerobic digestion? ❑ ❑ ❑ ❑
Were residuals <2% total solids (dry weight basis) (not diluted)? ❑ ❑ ❑ ❑
Was the test done between 10°C (50°F) and 30°C (86°F)? ❑ ❑ ❑ ❑
Was the temperature corrected to 20°C (68°F)? ❑ ❑ ❑ ❑
Was the sampling holding time <2 hours? ❑ ❑ ❑ ❑
Was the test started within 15 minutes of sampling or aeration maintained? ❑ ❑ ❑ ❑
Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of
total residual solids (dry weight basis)? ❑ ❑ ❑ ❑
❑ Option 5 - 14-Day Aerobic Process Y N NA NE
Were the residuals from aerobic digestion? ❑ ❑ ❑ ❑
Was the average residuals temperature higher than 45°C (113°F)? ❑ ❑ ❑ ❑
Were the residuals treated for 14 days and temperature maintained higher
than 40°C (104°F) for the 14-day period? ❑ ❑ ❑ ❑
❑ Option 6 - Alkaline Stabilization Y N NA NE
Was the pH of the residuals raised to >12 and maintained for two hours
without addition of more alkali? DODO
Did the pH of residuals remain at >11.5 an additional twenty-two hours
without the addition of more alkali? ❑ ❑ ❑ ❑
Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? DODO
❑ Option 7 - Drying of Stabilized Residuals Y N NA NE
The residuals do not contain unstabilized residuals? DODD
Were the residuals mixed with any other materials? If so, what? ❑ ❑ ❑ ❑
Were the residuals dried >75% total solids? DODO
❑ Option 8 - Drying of Unstabilized Residuals Y N NA NE
Were the residuals mixed with any other materials? ❑ ❑ ❑
Were the residuals dried >90% total solids? ® ❑ ❑ ❑
❑ Option 9/10 — Injection/ Incorporation of Residuals (Not commonly used - See White House Manual)
Page 3 of 4
Non -Discharge Compliance Inspection Report
Residuals Storage:
Describe storage: Covered concrete pad when storage is needed (when drier is down).
Number of days/weeks/months of storage: 3 to 4 weeks
Residuals Sampling: Y N NA
Is sampling adequate and representative? ❑ ❑ ❑
Describe Sampling:
Transport Vehicle: Y N NA
Is transport occurring at time of inspection? ❑ ❑ ❑
Are necessary records (i.e. permit & spill plan) present in vehicle? ID of observed velticle(s): ❑ ❑ ❑
Application Site(s)
Were application site(s) inspected? Ifso, please complete info below. ❑ Yes ❑ No
Is application occurring at the time of inspection? If no, note the date of the last event:
Weather Conditions:
❑ Sunny 0 Partly Cloudy
0 Windy (wind direction: )
❑ No Precipitation ❑ Drizzle
❑ Cloudy
❑ Breeze
❑ Rain
❑ Yes ❑ No
NE
NE
0 Overcast El Stormy
❑ Calm
❑ Cloudburst (If applicable, precipitation measurement: )
Weather Notes (i.e. Significant Changes, Forecasts, etc):
Temp. (° F): ❑ <32 ❑ 32 — 40 ❑ 40 — 60 ❑ 60 — 80
Permit and Spill Plan onsite during application? ❑ Yes ❑ No
Application Observations: [Type of application:
❑ >80
Liquid ❑ Cake (> 15% total solids) ❑ Other,
Site Owner(s):
Intended Crop: PAN Requirement:
Application Rate (tons or gallons/acre):
lbs/ac
Nutrient Content:
Application occurring at time of visit: ❑ Yes ❑ No
Application Method: ❑ Surface ❑ Incorp/Injection
Incorporation/Injection during visit: ❑ Yes ❑ No ❑ N/A
Vegetative Buffer description: ❑None ❑Grass ['Crop ❑ Shrub ❑
Tree ❑ Other
Current Field Conditions:
❑ Bare ❑ Stubble ❑ Planted (crop) ❑ Pasture
Soil Condition:
LI Dry ❑ Moist ❑ Wet 0 Saturated
❑ Not -Frozen 0 Frost ❑ Frozen ❑ Snow -Covered
Slope: ❑ 0-3% ❑ 3-6% ❑ 6-IO% 0 10-I8% ❑ >18%
Odor: ❑ None ❑ Mild 0 Moderate 0 Strong
Vectors: ❑ None ❑ Few ❑ Many 0 Excessive
Application Details: Y N NA NE
Application areas clearly marked? ❑ ❑ ❑ ❑
Application within authorized area? ❑ ❑ ❑ ❑
Application method appropriate? 0000
Application is even (no ponding)? 0000
Sufficient setbacks from wells? 0000
Sufficient setbacks from surface waters? ❑ ❑ ❑ ❑
Slopes>10% avoided (Surface App.) ? ❑ ❑ ❑ ❑
Slopes>18% avoided (Incorp/Inject) ? 0000
Incorpflnjection within time -frame? ❑ ❑ ❑ ❑
No evidence of shallow GW? 0000
Tracking is prevented? 0000
Biosolids run-off is prevented? 0000
Site Owner(s):
Intended Crop: PAN Requirement:
Application Rate (tons or gallons/acre):
lbs/ac
Nutrient Content:
Application occurring at time of visit: ❑ Yes El No
Application Method: 0 Surface 0 Incorp/Injection
Incorporation/Injection during visit: 0 Yes ❑ No ❑ N/A
Vegetative Buffer description: ❑None 0Grass ['Crop ❑ Shrub 0
Tree ❑ Other
Current Field Conditions:
❑ Bare ❑ Stubble 0 Planted (crop) 0 Pasture
Soil Condition:
❑ Dry 0 Moist ❑ Wet ❑ Saturated
❑ Not -Frozen ❑ Frost ❑ Frozen 0 Snow -Covered
Slope: ❑ 0-3% ❑ 3-6% ❑ 6-10% ❑ 10-18% ❑ >18%
Odor: 0 None ❑ Mild ❑ Moderate 0 Strong
Vectors: ❑ None 0 Few 0 Many ❑ Excessive
Application Details:
Application areas clearly marked?
Application within authorized area?
Application method appropriate?
Application is even (no ponding)?
Sufficient setbacks from wells?
Sufficient setbacks from surface waters?
Slopes > 10% avoided (Surface App.) ?
Slopes >18% avoided (Incorp/Inject) ?
Incorp./Injection within time -frame?
No evidence of shallow GW?
Tracking is prevented?
Biosolids run-off is prevented?
Y N NA NE
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O 000
DODO
O 000
O 000
O 000
O 000
O 000
O 000
O 000
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